We at Lavera Skin Care North America strongly support and commend the Environmental Working Group on their efforts to create awareness around skin care ingredients and lobby for change. We believe this effort is much needed here in the US to help women and men become more aware of what ingredients are going into their bodies. As part of our commitment to safe ingredients and products, we have our products certified by the BDIH, which requires our products are eco-friendly, are free of synthetic and petroleum-based ingredients, do not use genetically modified ingredients, and do not conduct animal testing. We have held this commitment to produce safe skin care products since Lavera's inception in 1987 - over 22 years!

In 2008 and 2009, Lavera products were given the highest rank for public safety by Oeko-Test Magazine out of over 33 mainstream and natural manufacturers tested - ahead of brands like Dr Hauschka, Weleda, Avede, Clinique, Keihls, to name a few. Oeko-Test Magazine is the consumer safety bible in Germany - an public safety organization that independantly tests all types of consumer products for consumer and environmental safety. For example, in August 2009, Oeko-Test published the results of their lab tests of 306 lipsticks from a wide range of manufacturers - 165 products received "unsatisfactory" or "poor" grades. We are pleased our lipsticks received a "sehr gut" (german for "very good") from this study.

The Environmental Working Group (EWG) Skin Deep Database is a site dedicated to providing consumers with information on the safety of cosmetic and personal care products. You can search a product or ingredient and a safety report is generated, including a rating system which ranks products and ingredients with a health score from 0 – 10, 0 being safest.

While the EWG's Skin Deep Database does provide valuable research into toxic ingredients, there are flaws in this rating system, often providing consumers with inadequate or incorrect information on brands, products and ingredients.

The ingredients supplied are voluntary, via an online submission form. Thus it relies on the individual submitting the products to ensure that all the ingredients and percentages have been entered correctly and completely. The minimum percentage value is 1% when many ingredients, especially hazardous ones, can be in quantities much lower than 1%. The system also allows the individual to preview the score as these entries are made.

Skin Deep's rating system does not distinguish between a botanical ingredient that is free from toxic ingredients, due to manufacturing or processing, and those that are contaminated. Nor do they differentiate between organic and natural, cosmetic and food-grade, natural and synthetic ingredients. This all makes a very big difference in determining a product's safety.

As for the Hazard Scores of individual ingredients, its quite confusing. "Fragrance" is a term required by the INCO labelling laws to indicate a product has one or more ingredients that impart an aroma. This is given a score by EWG of 8. Understandably for synthetic fragrances due to the likely present of phthalates in the scent formulation. However, "Fragrance" for Lavera products are also indicated as "natural essential oils", meaning Lavera only uses essential oils to impart a scent. But by listing fragrance at 1%, any natural product scented with essential oils are given the Hazard Score of 8.

Lavera Self Tanners have an ingredient named
eugenol. This is extracted from clove oil, used for hundreds of years as a flavor agent, antiseptic, and for medical purposes. In fact, up to 90% of clove oil is made up of Eugenol. This ingredient, along with other essential oils in Lavera products, is at <1% of the product composition. Yet Eugenol has a Hazard Ranking of 5, whereas an ingredient like propylparaben that is something we DON'T want in our cosmetics, gets a rating of 4. Given that the concentrations of "Fragrance", eugenol, citral, lemonene and coumarin - all natural plant extracts, with a total composition under 2% in the Self Tanner, it is hard to understand how the Hazard Score of 6 is derived.

As a consequence, manufacturers of safe, non-toxic products may carry higher (negative) rankings than they should due to the wording of an ingredient label or insufficient information on a particular ingredient used. From our subjective observation, European natural companies seem to suffer more. Dr. Hauschka products are listed with 35 products ranked 6 or higher, despite the fact they rank near or equally with Lavera in most of Oeko-Test's independant lab tests of the individual products.

A case in point: Sunscreen lotions chock full of ingredients with hazard scores ranging from 0 thru 9 are given overall rankings of 3, while a Dr. Hauschka all natural sunscreen lotion with 1 ingredient ranking 8 (Fragrance – from essential oils), is ranked 5 overall. Quite confusing and certainly does not help the cause of companies that are trying to look out for public safety.

Makers of products containing harmful chemicals can actually be rated as very safe (even at a 0 risk) because the submissions are taken at face value. Some may be given the same ranking as a truly nontoxic product because they use a miniscule amount of an all natural plant derived ingredient. We are not aware of any independant lab tests to verify the true composition of submitted products, unlike the results given by Oeko-Test magazine.

At this moment, even FDA regulations do not require full and complete disclosure of all ingredients in skin care or cosmetics, nor do they govern the issue of contaminants that may find their way into the product. For example, in September of 2009, the FDA released their own study that found lead in all 20 lipsticks they tested. Also, phthalates often do not show up on the ingredient list because it is lumped in with many other synthetic ingredients under the term "Fragrance" which we discussed earlier.

A global safety rating system for cosmetic and personal care products on a submission basis is highly complex and cannot be relied upon without careful scrutiny. At this time Skin Deep is best used as an instrument to help guide you toward products that are less hazardous. But the bottom line is not only READ THE LABELS, but also RESEARCH THE COMPANY. Find out more about the company who's brand you are purchasing - what is their commitment to product safety, how long have they been honoring this commitment?